Guide
SDS Binders and Digital Access: Meeting the Access Rule
OSHA requires that SDSs be readily accessible to employees in their work area during each shift. You can meet this with paper binders, electronic systems, or both, as long as no barrier stops employees from getting a sheet immediately and there is a backup plan if the system fails.
Last updated by SDS Lookup
The accessibility rule in plain terms
The HazCom standard says employers must maintain SDSs for each hazardous chemical and ensure they are readily accessible during each work shift to employees when they are in their work areas. Electronic access, microfiche and other alternatives to paper are allowed, but only if employees can get the information immediately in an emergency and there are no barriers to access. A system that needs a password the worker does not have, or that sits in a manager's office behind a locked door, does not meet the rule.
Paper binders
Binders are simple and work during power cuts. Their weaknesses are that they get out of date, lose pages, and are poorly indexed. To make a binder work:
- Put binders where employees actually work, not in a distant office.
- Use an index at the front, ordered by product name, with a section for each department if needed.
- Include the date you received each sheet.
- Assign someone to add new sheets and remove superseded ones.
- Check the binder against your chemical inventory at least once a year.
Electronic systems
Electronic systems can store thousands of sheets, support search by name or CAS number, and update automatically when suppliers issue revisions. They also support mobile devices, which is useful for workers who move around a large site. Risks include network failures, login problems, unfamiliar interfaces and the assumption that "somebody else" keeps it updated. If you use an electronic system:
- Make sure employees know how to find a sheet and have a device within reach.
- Provide a backup for outages, such as local copies on a tablet or printed sheets for the highest-risk products.
- Avoid log-in barriers for emergency access.
- Check the system's search by CAS number and synonyms; see CAS number.
- Test the system during drills.
A hybrid approach works well
Many facilities combine both: an electronic system for day-to-day searching and a paper set for emergencies kept at the main entrance, first-aid stations and chemical stores. Responders then have what they need even if the network is down. If your site is remote or has many mobile workers, think about offline-capable apps.
Audit checklist
- Can an employee on any shift find the sheet for a product in under a few minutes?
- Is there a sheet for every hazardous chemical in your inventory?
- Are sheets current and in the 16-section format?
- Do employees know where to find them? Ask them.
- Is there a backup for electronic outages?
- Is the archive plan consistent with record retention rules?
This list is also a good basis for the training required under HazCom training requirements.
Worked scenario: the network goes down
A warehouse uses a cloud SDS system accessed through tablets. During a storm the wi-fi and the internet connection fail while a forklift punctures a drum. The shift supervisor needs the sheet within minutes. If the site only relies on the network, the sheet cannot be reached. A site that has planned for this would have the sheets for its most hazardous products stored on the tablets themselves, a printed emergency set at the dock office and the main gate, and a note of the supplier's emergency number on each printed sheet.
The lesson is to test the failure case, not only the normal case. During your next drill, ask someone unfamiliar with the system to find a named sheet with the network switched off.
Contractors, visitors and shift workers
Access has to work for everyone who may be exposed: contract cleaners, maintenance crews, night shifts and temporary staff. Make sure each group knows where to find sheets, and that any log-in is available to them. Where several employers share a site, the host employer typically makes sheets available to contractors for the chemicals they might meet. See employee right to know and OSHA HazCom.
Frequently asked questions
Can I keep SDSs only on a computer?
Yes, if employees have immediate access during their shift without barriers and there is a backup for outages.
Where should the SDS binder be kept?
Where employees work and can reach it without asking permission, for example in the work area, not locked in a manager's office.
Do I need an SDS for every product in the building?
You need one for every hazardous chemical you use or store at work. Check consumer-product exemptions before leaving products out.
Can employees use their own phones to look up SDSs?
Relying only on workers' personal devices is risky, because access then depends on each worker's phone, battery and connection. Provide employer-controlled access and a backup.